Contempt of Courts Act, 1971 — Civil contempt — Compliance with directions of Supreme Court — Refund of stamp value — Subsequent statutory impediment — Moulding relief A. Civil contempt — Scope — Wilful disobedience In contempt proceedings, the Court examines whether there is wilful and deliberate disobedience of its directions. Where substantial compliance is shown and subsequent difficulties arise due to statutory provisions, the Court may mould relief without entering into disputed merits. (Paras 2, 3, 8)

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Contempt of Courts Act, 1971 — Civil contempt — Compliance with directions of Supreme Court — Refund of stamp value — Subsequent statutory impediment — Moulding relief

A. Civil contempt — Scope — Wilful disobedience
In contempt proceedings, the Court examines whether there is wilful and deliberate disobedience of its directions. Where substantial compliance is shown and subsequent difficulties arise due to statutory provisions, the Court may mould relief without entering into disputed merits.
(Paras 2, 3, 8)

B. Compliance with original judgment — Partial compliance admitted
Where the alleged contemnor had refunded the entire deposited amount with interest and paid additional compensation as directed, but failed to refund the cost of non-judicial stamps, the contempt allegation was confined to the limited issue of stamp value refund.
(Paras 2, 3)

C. Non-judicial stamp papers — Expiry — Statutory bar under Stamp Rules
The State authority rejected refund of the stamp value on the ground that under Rule 218 of the U.P. Stamp Rules, 1942, refund of physical non-judicial stamp papers is barred after expiry of eight years, and the petitioner’s claim was time-barred.
(Paras 4, 7)

D. Subsequent impleadment of State — Bona fide action — Unconditional apology
Where the State, after being impleaded, fairly conceded that rejection of refund was based on a bona fide interpretation of statutory rules and tendered an unconditional apology, the Court took the same on record.
(Paras 6, 7)

E. Contempt jurisdiction — Direction simpliciter — Refund ordered without adjudication on merits
Without entering into the merits of issues arising after disposal of the original civil appeals, the Court directed the State to refund the stamp value upon return of stamp papers, thereby disposing of the contempt petitions.
(Para 8)

F. Closure of contempt against original respondent
In view of the above direction, contempt petitions qua respondent no. 1 were ordered to be closed.
(Para 9)

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ANALYSIS

The Supreme Court was seized of civil contempt petitions alleging non-compliance with its earlier judgment dated 06.09.2024, which directed, inter alia, refund of the cost of non-judicial stamp papers to the petitioner (Paras 2–3).

It was undisputed that respondent no. 1 had substantially complied with the judgment by refunding the deposited amount with interest and paying additional compensation of Rs. 15 lakhs. The sole grievance pertained to non-refund of Rs. 3,99,100/- towards stamp value, where expired stamp papers were instead returned (Paras 3–4).

Upon rejection of refund by the Registration Department citing statutory limitation under Rule 218 of the U.P. Stamp Rules, the petitioner approached the Court through contempt jurisdiction (Paras 4–5). Recognising the peculiar situation, the Court permitted impleadment of the State of Uttar Pradesh (Para 6).

The State fairly admitted that its action was taken on a bona fide interpretation of the statutory rules, tendered an unconditional apology, and expressed readiness to comply with the Court’s directions (Para 7).

The Court consciously refrained from adjudicating the merits of the statutory dispute or limitation issue, and instead exercised its inherent and contempt jurisdiction to issue a direction simpliciter to refund the stamp value upon return of the stamp papers, thereby ensuring effective compliance with its earlier judgment and doing complete justice (Para 8).

Consequently, the contempt petitions against respondent no. 1 were closed (Para 9).

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RATIO DECIDENDI

In contempt proceedings, where substantial compliance with the original judgment is admitted and subsequent non-compliance arises due to statutory impediments acting bona fide, the Supreme Court may, without entering into the merits of such subsequent disputes, issue a direction simpliciter to ensure effective compliance with its earlier आदेश, and close contempt proceedings in the absence of wilful disobedience.